On Monday, January 30, 2023, President Joe Biden announced that the public health emergency (PHE) will end on May 11, 2023. There will be many changes as a result of the PHE ending. One in particular will be the delivery, coding and billing of telehealth services. CMS had expanded telehealth benefits temporarily during the PHE through the Corona Virus Waiver 1135. There is a 151-day transition period, after the end of the PHE, for the required changes to take place. For example, after the PHE ends audio-only evaluation & management services and virtual direct supervision will no longer be allowed. There are five new permanent telehealth codes and some of the temporary codes will be allowed through the 151-day transition period.
Here are a few key points that need to be assessed:
- Who is an eligible provider of telehealth services?
- What locations are eligible for telehealth services?
- What are the licensing and interstate requirements for providers delivering services cross-state?
- What is an eligible distant site vs. originating site?
- What Place of Service should be used?
- When is a modifier needed?
- What preventive services can be provided through telehealth?
- Documentation requirements for telehealth?
Start planning your transition of telehealth services now. Some resources to review are:
- Corona Virus Waivers – https://www.cms.gov/coronavirus-waivers
- List of telehealth services codes – https://www.cms.gov/medicare/medicare-general-information/telehealth/telehealth-codes –> see “List of Telehealth Services for Calendar Year 2023 (ZIP)”
- Telehealth licensing requirements – https://telehealth.hhs.gov/providers/policy-changes-during-the-covid-19-public-health-emergency/telehealth-licensing-requirements-and-interstate-compacts/